The EU’s new MRV regulation for non-CO2 emissions is the single most significant policy shift for aviation sustainability in years. To cut through the complexity, we sat down with Dimitar Nikov, a key policy officer at the European Commission’s DG CLIMA, to get direct answers to the industry’s most pressing questions.
In this exclusive interview, Dimitar breaks down the timeline for the crucial NEATS platform, clarifies the business case for data strategy, and offers a glimpse into a future where contrails could carry a carbon price.
The Strategic View: Why Now and What’s Next?
We started with the big picture. With so much focus on CO2, why is the EU making a regulatory push on non-CO2 effects right now?
“The MRV is above all a regulatory response to the greater scientific awareness and consensus on the overall net warming effect of aviation’s non-CO2 impacts. It was specifically requested by EU co-legislators to create a robust data framework. This isn’t just about science; it’s about building the foundation to inform future mitigation policies. We have a report due in 2027 that will assess the results and determine how we can extend the EU ETS to cover these effects.”
So, looking ahead to post-2027, what does the future hold? Are we moving towards active contrail management as a compliance requirement?
“All options are still open, but mitigation is recognized as being needed. Our 2040 climate targets explicitly identify aviation’s non-CO2 effects as an area for action. The long-term goal is to explore cost-beneficial mitigation options. This will eventually evolve from passive monitoring to active management, where we can implement flight adjustments to avoid the most harmful, persistent contrails.”
The Operational Playbook: Data, Fuel, and the NEATS Platform
Let’s get into the operational details. The big question from every airline is about the NEATS platform. When will it be ready, and what can we expect?
“We are about to launch a trial period with Eurocontrol in mid-September 2025. This will start with basic data upload capabilities. Full calculation and reporting functionalities are expected to be online by the end of 2025. The system is designed for airlines, competent authorities, and verifiers.”
One of the biggest operational hurdles is getting detailed fuel properties. How does the Commission expect airlines to manage this?
“We acknowledge the challenge. That’s why we’ve introduced a time-limited flexibility for 2025 and 2026. Airlines can report the single maximum value for a parameter, like aromatics, that was observed across all fuel batches delivered to a specific airport over the year. It’s a practical starting point, but the goal is to preserve the incentive for airlines to eventually provide more granular, per-flight data.”
Speaking of data, what is the core business case for an airline to invest in providing high-quality primary data versus just using the defaults?
“The incentive is clear: better data means a better, more accurate climate profile for your flights. Using conservative default values is a common practice to encourage the use of better data. An airline that provides precise, primary data will be able to showcase its superior environmental performance, which is a significant advantage as we move towards potential pricing and mitigation schemes.”
The Compliance Roadmap: Deadlines and Strategy
For compliance teams, what are the key takeaways? Is there any strategic advantage to using default values to set a high baseline for the future?
“That’s a step too far. We don’t want to preempt future regulation, but inflating numbers is never beneficial, especially in a transparent system where the calculations are clear. We know that figures generated with primary data will be better than those from defaults. The key deadline for compliance teams is the end of 2025, when the NEATS system is expected to be fully operational for reporting.”
And how much flexibility do airlines have in their reporting? Can they mix primary and secondary data?
“Yes, absolutely. The system is designed for flexibility. An airline can choose its approach by aircraft type. For instance, you could provide detailed primary data for your newest, most efficient aircraft while using secondary data for older fleet types. It’s not an all-or-nothing system.”
This conversation makes it clear that the next two years are a critical learning period for both regulators and airlines. The data gathered will not only fulfill a reporting mandate but will actively shape the future of climate policy in aviation. The airlines that engage early and build a robust data strategy will be best positioned for what comes next.
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